TP Adjustment - comparable selection - The Tribunal upheld the ...

Tribunal Rules on Comparable Companies for Benchmarking; Includes HSIL, Excludes Cera for Insufficient Revenue Data.

May 13, 2024

Case Laws     Income Tax     AT

TP Adjustment - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in manufacturing and selling sanitaryware products. Despite some functional diversity, the Tribunal found the core activities sufficiently similar for comparison purposes. - The Tribunal directed the exclusion of Cera Sanitaryware Limited from the list of comparables. It noted that while the functions performed by Cera Sanitaryware Limited were similar to the Assessee's, the lack of proportionate revenue data for different activities made it unreliable for benchmarking purposes.

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